Case Summary (G.R. No. 170634)
Criminal Allegations
The amended informations in the criminal cases charged Buado with two counts of rape:
- Criminal Case No. 912-V-99: Alleging the rape of ten-year-old AAA in April 1999.
- Criminal Case No. 974-V-99: Alleging the rape of eight-year-old BBB on November 10, 1999.
Evidence of the Prosecution
The prosecution presented eight witnesses, including the two victims, their mother, and medical experts. The testimonies revealed the horrifying acts committed by the accused. AAA recounted how Buado had sexually assaulted her numerous times, beginning when she was still in Grade I, while BBB described a specific incident on November 10, 1999, where she was raped after being commanded to undress. Both girls testified to the fear they experienced due to their father's abusive behavior, which contributed to their silence prior to reporting the abuse.
Defense Strategy
Buado served as his own witness, denying the charges and attributing BBB's injuries to supposed rape by his drug-addicted son. He further attempted to discredit the victims' testimonies by alleging motives of revenge against him from his wife, CCC. His defense also highlighted alleged marital conflicts and his behavior as a "strict disciplinarian."
Rulings of the Trial Court
The Regional Trial Court (RTC) convicted Buado of two counts of rape, imposing the death penalty due to the heinous nature of the crimes and the relationships involved. The RTC ordered him to pay civil, moral, and exemplary damages to the victims.
Court of Appeals Decision
On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction but modified the penalty to reclusion perpetua for the first count of rape, citing a lack of sufficient evidence of the victim's minority to support a conviction for qualified rape. However, the penalty for the second count concerning BBB was affirmed as these were established.
Issues on Appeal
Buado's appeal raised two primary issues:
- Whether his guilt was proven beyond reasonable doubt.
- Whether the imposition of the death penalty was warranted given the prosecution's claims regarding the qualifying circumstances of relationship and minority.
Ruling of the Supreme Court
The Supreme Court upheld the findings of the lower courts, emphasizing several legal principles related to the burden of proof in rape cases, especially regarding credibility. Testimonies of AAA and BBB were found credible and consistent, which had been pivotal in affirming their experiences of rape. The Court rejected Buado's arguments regarding the credibility of the victims and the lack of immediate reporting. It noted that fear of retaliation was a significant factor in their delayed disclosure.
Final Disposition
The Court modified the penalties as follows:
- Criminal Case No. 912-V-99: Reduced to reclusion perpetua with the corresponding civil liabilities.
- Criminal Case No. 974-V-99: The previously
Case Syllabus (G.R. No. 170634)
Overview
- This case revolves around the horrific acts of incestuous rape committed by Pedro Buado, Jr. against his two minor daughters, AAA and BBB.
- The trial court sentenced Buado to death for each count of rape, but the subsequent prohibition of the death penalty affected the final ruling.
- The case highlights the critical issues surrounding the credibility of child witnesses, the nature of rape, and the application of laws concerning minors.
Antecedents
- Criminal Charges:
- Criminal Case No. 912-V-99: Alleged rape of AAA, a 10-year-old, in April 1999.
- Criminal Case No. 974-V-99: Alleged rape of BBB, an 8-year-old, on November 10, 1999.
- Accused's Relationship: Pedro Buado, Jr. is the biological father of both victims, and he was legally married to their mother, CCC.
- Living Conditions: The family resided in Valenzuela City, Metro Manila, with 13 children, including AAA and BBB.
Evidence of the Prosecution
- Witnesses Presented: The prosecution called eight witnesses, including the victims, their mother, an older sister, medical doctors, and a police officer.
- Testimonies of AAA and BBB:
- AAA's Account:
- Summoned home during a family gathering, she was assaulted by her father.
- Reported multiple incidents of sexual abuse beginning when she was in Grade I.
- Described threats from Buado, which instilled fear and prevented her from reporting earlier.
- BBB's Account:
- On the date of the incident, her father commanded her to undress and assaulted her on a plywood surface.
- She revealed that the assaults occurred multiple t
- AAA's Account: